Testimony given before the Environmental Protection Agency regarding animal testing mandate for specific chemicals

March 31, 2009

On February 14, 2008, the National Institutes of Health (NIH) and the Environmental Protection Agency (EPA) held a press conference announcing a new collaborative effort to use state of the art technology to test for chemical toxicity.

These pioneering procedures, which include using robotics and human cell cultures, have brought us to the dawn of a new era in scientific experimentation and toxicity safety testing. The EPA rules we are here today to discuss, however, drag us back into the darkness, for exposing animals to lethal doses of chemicals is not a thing of the 21st Century.

Toxicity testing using animals is “... clearly quite expensive, it is time consuming, it uses animals in large numbers and it doesn't always predict which chemicals would be harmful to humans.”

These are the words of Dr. Francis Collins, the then Director of The National Human Genome Research Institute, speaking at the NIH/EPA teleconference on the 14th of last year.

Dr. Collins continued: “There are differences between species. We are not rats and we are not even other primates.”

Speaking directly to the point of the NIH/EPA joint venture that would act as a replacement for animal testing, Dr. Collins said: “And so the desire here is to try to see if we could do better.”

Samuel Wilson, former director of the NIH National Institute of Environmental Health Sciences, who was also at the NIH/EPA press conference, echoed Dr. Collins statements. As quoted in Scientific American, Feb. 15, 2008, Wilson said: “This sort of "high-throughput" testing will enable researchers to generate more data relevant to humans, and at the same time reduce the amount of animal experimentation. The cross-species extrapolation from animals to humans is "not always as precise as it should be," Wilson said. "This collaboration is a milestone because it gives us the ability to apply a new generation of approaches to determining toxicities.”

Robert Kavlock, Director of the National Center for Computational Toxicology at EPA, was quoted in the same article and joined his colleagues in expressing the inherent flaws with animal toxicity testing by saying “...that it also is expensive, inefficient and is not always an accurate indicator of how a substance will affect humans.”

The NIH/EPA are not alone in seeking a more advantageous method to test for toxicity; another ground breaking technological advancement are “biochips” - The MetaChip (Metabolizing Enzyme Toxicology Assay Chip) and the DataChip (Data Analysis Toxicology Assay Chip), which were created by researchers at Rensselaer Polytechnic Institute, the University of California at Berkeley, and Solidus Biosciences Inc.

Both chips are glass slides, with the MetaChip containing human enzymes, while the DataChip contains cell cultures. As was reported in the National Institute of Environmental Health Sciences News of March 2008: “When the two slides are sandwiched together and incubated, they mimic the body’s reaction to compounds. If the cells stop growing, appear sick or die, it’s an indication that a toxin is present.”

The headline for the story on biochips in Scientific American, December 21, 2007 read: “Biochips promise to deliver better drug and chemical testing, cutting costs and nixing the need for most animal testing.”

Dr. Collins set the correct ethical and scientific tone when he said that the desire is to “do better,” yet the rules we are discussing today fail this. They do not do better. These animal tests will be expensive. They will take a great deal of time. They will destroy the lives of thousands of animals, and they will not produce the best hazard assessments for human health and the environment.

In science, we must always press forward, pushing the frontiers of our knowledge and our ethics to new heights, topping each crowning moment with the race to the next summit. With so much technology within our grasp, is it not better to apply this superior technology to the testing of HPV chemicals rather than waste so much time, money and life?

Our argument, in its most direct and uncomplicated expression, is that we do it better.

Sincerely,

Stuart Chaifetz
Program Director, The ARISE Campaign
PO Box 174 Englishtown, NJ 07726
732 561 4642